Offshore chemical regulations FAQ`s

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OCR FAQ’S
Questions:
1. SHIPPING AND MIXING - How are chemical mixtures permitted and reported?
2. ENVIRONMENTAL IMPACT ASSESSMENT – Pipeline Discharge & Scale Squeeze
Operations - How is the Risk Quotient (RQ) calculated for pipeline discharge
operations?
3. USE OF EXISTING STOCKS OF EXPIRED PRODUCTS - Can existing stocks of
expired chemicals be used?
4. DIESEL BIOCIDES - Is the use of biocide in fuel subject to the Regulations?
5. USE OF DIESEL AS A SOLVENT OR CARRIER - Is the use of diesel as a solvent or
carrier subject to the Regulations?
6. CHEMICAL CUTTERS - Is the use of chemical cutters subject to the Regulations?
7. CHEMICALS SUPPLIED FROM ONSHORE FACILITIES – Are chemicals that are
supplied from onshore facilities subject to the Regulations?
8. CHEMICAL DISPERSANTS – What is the procedure for applying to use chemical
dispersants?
9. MULTIPLE WELL TESTING OF DIFFERENT STRATA – Does the EWT threshold of
production of oil in excess of 2000 tonnes and/or for a flow period of more than 96
hours or the production of gas for more than a 96 hour flow period apply to the
sum of all zones tested?
10. APPROVAL FOR THE DISCHARGE OF SET DOWNHOLE CHEMICAL PRODUCTS What is the procedure for obtaining approval for the discharge of set downhole
chemical products?
11. ZERO DISCHARGE BREACH - If there is a discharge of a chemical currently on a
permit with a use quantity but a zero discharge would this constitute a breach of
permit conditions if the discharge was under 10%?
12. SHALLOW GAS DIVERTER OPERATIONS - Is potential chemical use and discharge
associated with shallow gas diverter operations subject to the Regulations?
13. CLOSED UTILITY SYSTEMS - When is the use and discharge of chemicals in
closed utility systems subject to the Regulations?
14. PRODUCTS POSING LITTLE OR NO RISK (PLONORs) - How are PLONOR
chemicals assessed?
15. LUBRICANTS AND HYDRAULIC FLUIDS – When is the use and discharge of
lubricants and hydraulic fluids subject to the Regulations?
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16. TRACER AND RADIOACTIVE CHEMICALS - What is the procedure for obtaining
approval for the use and discharge of tracer chemicals?
17. MAINTENANCE CHEMICALS - What types of chemicals can be classified as being
used for maintenance?
18. Will the regulations cover risks associated with transport to (and, in some cases,
from) the platform?
19. What would DECC expect to see in an ES in relation to chemical use and
discharge, given that it can be prepared a year in advance of offshore operations?
20. When an application is submitted, do FRS / CEFAS have sole responsibility for the
evaluation of the risk assessment, or does DECC have any involvement?
21. What method of analysis is appropriate to determine the content of hydrocarbon
chemicals and substitute hydrocarbon chemicals?
22. Well bore clean-up discharge; can waste streams be put into temporary storage
prior to discharge, and still qualify as an operational discharge?
23. TRIAL CHEMICALS – Is the use and/or discharge of trial chemicals covered by the
Regulations?
24. Pipe Dopes containing Lead – Can they be used in the UKCS?
25. The use of chemicals in shallow drilling
26. The use of abrasives during well abandonment operations
27. DISCHARGE OF CUTTINGS CONTAMINATED WITH ORGANIC PHASE DRILLING FLUIDS
Answers:
1. SHIPPING AND MIXING - How are chemical mixtures permitted and reported?
Operators are allowed to ship chemicals to the installation that are not listed on their permit,
however chemicals must be on the permit before use although the mixing of any chemicals/muds
in the pits is allowed.
In recognition of Health and Safety requirements/concerns, pre-mixing or pre-diluting of products
onshore is acceptable providing all products in the mixture are registered with CEFAS. All
products should be listed on the permit and should also be reported to EEMS as normal. Both
the applications and the returns must relate to a specific certified chemical, not the amended form
of the chemical i.e. if a chemical is certified as a 100% solid, the application should indicate how
much of the 100% product will be used and/or discharged, even if it is supplied to the installation
in a different format e.g. a 50% solution.
The Offshore Inspectorate will be able to check how the concentrate is being used when they are
offshore. The operator is obliged to use the product as specified in the certification
documentation.
The Portal (and non-Portal) application entries and the EEMS return entries should relate to the
form of the chemical that has been certified. The chemical manufacturer or supplier who certified
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the product will specify the formulation that has been submitted for certification. All applications
and returns should then be related to that specification.
The use of any chemicals generated offshore must be recorded in the PON15D. In the case of
sodium hypochlorite, it is the ‘available chlorine’ in the product which is recorded, not the volume
of the product.
2. ENVIRONMENTAL IMPACT ASSESSMENT – Pipeline Discharge & Scale Squeeze
Operations - How is the Risk Quotient (RQ) calculated for pipeline discharge
operations?
The CHARM Implementation Network (CIN) suggested approach to calculate a risk quotient (RQ)
for Pipeline Discharge operations:
The RQ can be obtained using the Completion and Work-Over algorithm for which the entries
would be as follows:
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Set Chemical type to surface and well cleaning;
Set Dose as the dose of substance applied to pipeline;
Force Dilution Factor to 0.001;
Set Fraction released to unity (1);
Enter Toxicity information from the data sheet;
The RQ output can be used as an HQ, for ranking and comparison purposes;
For a ‘real’ risk quotient calculation it would be necessary to use more detailed
hydrodynamic modelling. There is a range of dilution models available to the modeller.
The CHARM Implementation Network (CIN) suggested approach to calculate a hazard quotient
(HQ) for Scale Squeeze operations:



Select the “Completion and Work-over” algorithm;
Set Type of chemical’ to ‘Other completion/work-over chemical’;
Set the dose as the initial concentration in the injection in units of mg l-1;
Set the fraction of chemical discharged to 0.3;
Accept the RQ output as an HQ and use this for ranking and comparison purposes
The CIN suggested approach to calculate a risk quotient (RQ) for scale squeeze operations:
The dose should be the best estimate of the peak concentration (in the initial return slug);
Set ‘Fraction released’ to unity (1);
Calculate the batch-wise dilution factors using the tables at the back of the manual if for any
completion and work-over chemical;
It will usually be necessary to use the “Standard” Production Chemical algorithm to model the tail
of the return profile.
There are not definitive methods for carrying out a chemical risk assessment of a pipeline
discharge or scale squeeze operation, and the Department will consider alternative risk
assessment methods/models when presented with the appropriate scientific evidence.
3. USE OF EXISTING STOCKS OF EXPIRED PRODUCTS - Can existing stocks of
expired chemicals be used?
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a) When the HOCNF certification of a product expires, the product will be removed
from the CEFAS lists of approved chemicals. Applications for chemical permits
must not include "expired" products that are no longer on the approved lists.
b) All products included in a permit application must be on the approved lists at the
time of submission of the application. If there are any expired products included
in an application, they will be rejected and the applicant will be requested to seek
alternative products.
c) If a product will expire during the period between submission of the application
and the date of commencement of the requested permit, the Department will
require confirmation that the product has been, or will be, submitted for recertification. If an applicant fails to provide this confirmation, the product will be
rejected and the applicant will be requested to seek an alternative product.
d) If an applicant provides the requested confirmation under Paragraph c, but the
re-certification process has not been completed prior to commencement of the
works, the applicant will be able to use existing stocks of the expired product,
subject to the conditions outlined in Paragraphs f-i below.
e) If a product will expire during the period of validity of the requested permit, the
applicant will be able to use existing stocks of the expired product, subject to the
conditions outlined in Paragraphs f-i below.
f)
All chemical permits will contain a condition requiring the permit holder to notify
the Department in advance of any proposed use of existing stocks of an expired
product. The notification will be filed/stored alongside the permit, so that use of
the product is not interpreted as a breach of the permit conditions when the
Department reviews the (EEMS) permit return.
g) Existing stocks of an expired product must be the property of the permit holder or
an agent undertaking the operation on behalf of the permit holder (e.g. a drilling
or pipeline installation/testing contractor). There must be a clear audit trail to
confirm ownership.
h) Existing stocks of an expired product can be held at the site of the works; at any
onshore premises operated by the permit holder; at any onshore premises
operated by an agent undertaking the operation on behalf of the permit holder; or
at any onshore premises operated by any other agent acting on behalf of the
permit holder (e.g. a harbour authority, supply base operator, supply vessel
operator or even the chemical supplier). Wherever the stocks are held, there
must be a clear audit trail to confirm ownership of the chemical mentioned in
Paragraph g. It is also recommended that copies of the chemical permit and the
notification referred to in Paragraph f should be held by any agent that could be
involved in the provision of an expired product.
i)
The permit holder, or the agent undertaking the operation on behalf of the permit
holder, is not allowed to obtain additional stocks of an expired product from any
third party. Inspectors appointed under the Offshore Chemicals Regulations
2002 will be entitled to request copies of the documentation relating to the audit
trail to confirm ownership of stocks of expired products. Obtaining additional
stocks of a product after it has expired will be treated as a serious offence.
4. DIESEL BIOCIDES - Is the use of biocide in fuel subject to the Regulations?
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There is no requirement to include biocides added to diesel (or other fuels) in chemical permits.
This decision recognises that biocide use in fuels does not constitute an "operational use" of a
chemical, and takes account of the OSPAR "Common interpretation on which chemicals are
covered and not covered by the harmonised mandatory control system under OSPAR Decision
2000/2".
5. USE OF DIESEL AS A SOLVENT OR CARRIER - Is the use of diesel as a solvent or
carrier subject to the Regulations?
Diesel is occasionally used operationally as a solvent or carrier, for example during squeeze
operations. In all cases, the diesel is not discharged to the sea, and it is usually left down-hole or
combined with the produced fluids.
Diesel is not notified and included in the approved chemical lists, and there is no intention to ask
suppliers to submit diesel for classification. It will therefore not be included on the drop down
chemical lists that are used to complete the online applications. All operational use of diesel
should be explained in the justification.
As diesel will not be included in the chemical tables that will form the basis of the chemical permit,
its use should not be reported in the term or annual return.
6. CHEMICAL CUTTERS - Is the use of chemical cutters subject to the Regulations?
Chemicals used to cut well tubulars are not covered by either the OCNS approval procedure or
the chemical permitting system.
The most commonly-used chemical cutters are based on bromine trifluoride which, when used
under high pressure, becomes a gas that is directed at the surface of the pipes. In view of the
small quantities of chemical involved and the minimal environmental impact, cutters based on
bromine trifluoride have been excluded from the chemical permitting system.
The Department will consider other chemical cutters on a case-by-case basis, and will advise
operators accordingly.
7. CHEMICALS SUPPLIED FROM ONSHORE FACILITIES – Are chemicals that are
supplied from onshore facilities subject to the Regulations?
Chemicals supplied from onshore facilities via a pipeline or umbilical, which are then injected into
the export stream and returned onshore for regeneration, are not covered by the Offshore
Chemicals Regulations 2002, and do not require to be on the approved lists. This also applies to
pipe dopes/dope substitutes/dope-less friction controlling lubricants when they are applied
onshore and there is no requirement to replace the chemicals offshore. Where there may be a
requirement to apply dope substitutes or dope-less friction controlling lubricants offshore, the
chemicals are covered by the chemical permitting system and therefore are covered by the
Regulations.
However, where there is offshore top-up of chemicals supplied directly from onshore, the offshore
use must be included in the chemical permit application, as this is considered to be an
operational use covered by the OSPAR Harmonised Mandatory Control Scheme (HMCS).
Similarly, where there is offshore discharge of chemicals supplied directly from onshore, the
discharge must be included in the chemical permit application.
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8. CHEMICAL DISPERSANTS – What is the procedure for applying to use chemical
dispersants?
Produced water sheens are occasional by-products of the production and processing of crude oil
offshore. They are particularly prevalent in calm weather conditions and can be seen at levels as
low as 10mg/l or less. For the majority of produced water sheens, the use of a chemical
dispersant is not considered to be best practicable environmental option (BPEO). Improved
topsides processing is a preferred route to preventing sheen formation. Nonetheless, there are
circumstances in which the Department will grant permission for a dispersant to be used as a
topsides produced water treatment. These circumstances would involve sheens that are routinely
present in areas of environmental sensitivity and/or in areas where there are routinely significant
numbers of birds present on the surface of the water surrounding the platform.
In all cases, permission to use a chemical dispersant, for the purpose of dispersing a routinely
observed produced water sheen, should be sought by application to the Department as part of a
chemical permit submission or variation. Since it is not always easy for permit reviewers to
identify chemicals intended for use as chemical dispersants, applicants must highlight the fact
that a chemical dispersant is intended to be used and provide a full justification for it's use. All
applications to use chemical dispersants will be subject to the normal review process by the
Department and it's statutory consultees. In addition, use of any chemical dispersant must be
declared in an application for a permit to discharge produced water granted under The Offshore
Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2004.
9. MULTIPLE WELL TESTING OF DIFFERENT STRATA – Does the EWT threshold of
production of oil in excess of 2000 tonnes and/or for a flow period of more than 96
hours or the production of gas for more than a 96 hour flow period apply to the
sum of all zones tested?
Tests of distinct zones within a well are treated separately, and therefore there is not a cumulative
process to determine whether they qualify as an EWT. In all cases, the final decision will rest
with LED, and therefore the Consents Team should be consulted if in any doubt, as the
environmental regime for EWTs will only kick-in if there is an EWT consent requirement.
If none of the potential tests within each zone exceed the EWT threshold it will be unnecessary
to seek a separate Direction for an EWT. Nevertheless, full details of the test regime should be
included in the request for a Direction for the well (the PON15B).
10. APPROVAL FOR THE DISCHARGE OF SET DOWNHOLE CHEMICAL PRODUCTS What is the procedure for obtaining approval for the discharge of set downhole
chemical products?
When Liquid stone is mixed with a liquid stone activator and then pumped downhole over the
perforations, the product sets hard and the excess is milled out using coiled tubing and
discharged to sea.
The most appropriate way to deal with this discharge is to permit the 'Use' of product with 'zero'
discharge. Any solid discharged should then be quantified and explained in Section C of the
PON15B.
This approach could be mirrored for other solids that are routinely pumped downhole as liquids
and then milled out later as solids. The common example is cement which is often milled days,
weeks or months after setting down hole. Currently approval can be gained for the use and
discharge of liquid cement but not solids.
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Liquid stone should be included as 'use' under section G and the discharge of the milled solidified
material should be detailed in section C Justification with a quantification of the likely amounts.
The discharge column in section G should be 0 with an asterisk to detail the only discharge will
be as milled solidified material and that further details are provided in section C.
11. ZERO DISCHARGE BREACH - If there is a discharge of a chemical currently on a
permit with a use quantity but a zero discharge would this constitute a breach of
permit conditions if the discharge was under 10%?
Condition 3 of the schedule of permit conditions currently states:3)
Permitted quantities of chemicals
The permit holder shall ensure that the quantities of all chemicals used or discharged during the
course of the operations covered by the permit do not exceed by more than 10% the quantities
detailed in the permit application. In the event that the permit holder becomes aware that the use
or discharge of any chemical may exceed the quantity detailed in the permit application by more
than 10%, the permit holder must notify the Department within two working days.
The above condition refers to an increase in discharge by no more than 10% of that permitted
and must be notified within 2 working days to DECC. It is of the opinion that moving from zero
discharge to making a discharge would be a variation in the fate of the chemical and not simply
an increase in discharge and therefore would not be permitted under condition 3. This opinion is
based on the fact that moving from no discharge to undertaking a discharge may require a
CHARM calculation and may result in a different assessment of the likely impact.
Therefore in DECC's opinion, if a discharge of a chemical is made where the original application
stated zero discharge, then this would constitute a breach of permit conditions.
12. SHALLOW GAS DIVERTER OPERATIONS - Is potential chemical use and discharge
associated with shallow gas diverter operations subject to the Regulations?
When drilling wells at some locations, it will be normal practice to operate a shallow gas diverter
that uses bursting discs to alleviate excess pressure and ensure the safety of the facility. The
diverter is only used for the well section where the shallow gas is expected, and the bursting
discs are thin flexible metal and very sensitive to defects and mechanical damage.
Prior to drilling operations, the discs are normally tested with seawater, and they may burst with
discharge to the sea. Providing the tests are undertaken using seawater and do not involve the
use of any chemicals, the tests do not require to be permitted. During the drilling operations, the
discs are designed to rupture if there is excessive pressure, which could result from infrequent
and unforeseen operating conditions, such as cuttings packing-off in the hole, or from shallow gas
incidents. Rupturing of the discs will result in the discharge of drilling fluids to the sea. At the end
of the relevant well section, there will also usually be a further discharge of drilling fluids, when
the riser is disconnected to replace the shallow gas diverter with a BOP. The latter is normal
operating practice, as it is not possible to recycle the mud from the base of the riser, but the
discharge is usually made at the sea surface rather than via the usual sub-surface cuttings
disposal chute.
All potential chemical use and discharge associated with shallow gas diverter operations should
be included in the chemical permit application, and explained in a separate section of the
Justification. If the discharges will definitely take place (riser disconnect), this would constitute a
primary chemical use and discharge. If the discharges will only take place if there is a pressure
event (bursting disc), this would constitute a contingency use and discharge. Inclusion of the
potential use and discharge in the application will avoid any PON1 or Non-conformance reporting
requirements.
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13. CLOSED UTILITY SYSTEMS - When is the use and discharge of chemicals in
closed utility systems subject to the Regulations?
The contents of closed utility systems, such as heating, cooling and firewater systems, are not
covered by the OSPAR Harmonised Mandatory Control Scheme (HMCS), and are not covered by
the Offshore Chemicals Regulations 2002. As the chemicals are not covered by the HMCS, the
offshore top-up of closed utility systems does not require to be detailed as a chemical use in
permit applications. The drain-down of closed utility systems for disposal of the chemicals is not
considered to be an operational discharge, and does not require to be detailed as a discharge in
permit applications. Where chemicals used in closed utility systems are not covered by a
chemical permit, any chemicals drained from the systems should be returned to the shore for
disposal.
However, if there is a regular requirement to renew the contents of closed utility systems, it is
recommended that the operations are included in production chemical permits. This will simplify
the approval process for any proposed offshore discharges. However it will make it necessary to
use chemicals that are on the approved lists.
14. PRODUCTS POSING LITTLE OR NO RISK (PLONORs) - How are PLONOR
chemicals assessed?
Products that consist entirely of PLONOR substances, or aqueous dilutions thereof, will not have
an ecotoxicological data set so they cannot be assessed using CHARM and ranked against other
products. Such products will be listed against their suppliers in the List of Notified Chemicals and
identified as consisting entirely of PLONORs.
15. LUBRICANTS AND HYDRAULIC FLUIDS – When is the use and discharge of
lubricants and hydraulic fluids subject to the Regulations?
Section 3.3 of the Guidance Notes for the Offshore Chemicals Regulations indicates that the
regulations are intended to apply to those "operational" chemicals, which are used in such a way
as to result in actual or possible discharges, i.e. "operational" releases into the sea.
The small losses of lubricants that occur during the operation of production-related equipment or
machinery are not covered by the chemical permitting system, and the lubricants do not require to
be notified and included in the approved chemical lists. Thus, valve lubricants, wire-line
lubricants etc, are excluded.
Hydraulic fluids used in enclosed systems, where there is no deliberate operational discharge,
are not covered by the chemical permitting system. Thus fluids used in Xmas Trees, and BlowOut Preventers (BOP) on platform development wells are excluded.
Hydraulic fluids which are only discharged in an emergency are not covered by the chemical
permitting system. Thus fluids that are used in down-hole safety valves on platform development
wells are also excluded.
Hydraulic fluids that are used in control devices that are routinely activated, resulting in a
discharge to the environment, are covered by the chemical permitting system, and the chemicals
must be notified and included in the approved chemical lists. Thus, fluids used in the well control
devices that are normally operated by Mobile Offshore Drilling Units (MODU) must be approved
and included in chemical permit applications.
Notwithstanding the chemical permitting requirements outlined above, it should be noted that at
the meeting of the OSPAR Offshore Industry Committee (OIC) in Cadiz in February 2002, it was
confirmed that the Harmonised Mandatory Control Scheme (HMCS) applied to all hydraulic fluids
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used to control wellheads, blow-out preventers and subsea valves. All hydraulic fluids used in
these systems must therefore be notified and included in the approved chemical lists.
16. TRACER AND RADIOACTIVE CHEMICALS - What is the procedure for obtaining
approval for the use and discharge of tracer chemicals?
TRACER CHEMICALS - What is the procedure for obtaining approval for the use and discharge
of non-radioactive tracer chemicals?
Chemicals that are to be used as tracers which are NOT classified as radioactive, are subject to
the Offshore Chemical Regulations 2002 and must be registered with CEFAS, by providing the
necessary ecotox information as required by those Regulations. In addition, the operator must be
granted a permit to use and/or discharge those chemicals before they may be used/discharged
offshore.
However, in the case of operational use of tracer chemicals in “trivial” quantities it is acceptable to
provide temporary approval for tracer materials that fall into this category, rather than obtaining
full certification. This procedure ensures that operators have to come to the Department prior to
each proposed use (to renew the temporary approval) so that the Department can ensure that the
scale of use is trivial.
RADIOACTIVE TRACERS – What is the process for gaining approval to use and/or discharge
radioactive tracer chemicals?
Chemicals that are to be used as tracers that are classified as radioactive and have a valid
Registration and Authorisation Permit under the Radioactive Substances Act 1993 (RSA93),
issued by either the EA or SEPA for use/discharge into the marine environment of the UKCS, do
NOT require to be registered with CEFAS under the Offshore Chemical Regulations 2002.
However, the Operator will be required to ensure that a full justification of the use/discharge of the
product is included in the justification section of the relevant PON15, including the name of the
product to be used and the anticipated volumes to be used and/or discharged. Any additional
use/discharge must also be notified in a Variation to the relevant PON. The Operator will also be
required to notify the actual volumes used and discharged to EEMS under the Radioactive
Section.
17. MAINTENANCE CHEMICALS - What types of chemicals can be classified as being
used for maintenance?
There are some chemicals that are considered to be for maintenance rather than operational use,
and consequently there is no requirement to register these with CEFAS. Neither is there a
requirement to include them in the chemical permit or to include them in the chemical permit
returns.
Examples of these are: - chemicals used to prevent machinery or installation corrosion; products
classified as coatings that are used to protect internal and external surfaces of coiled tubing from
corrosion and erosion damage; products classified as “locking” compounds that are used as a
material to bond casing threads or fittings
Incidental discharges of such chemicals during treatment operations do not require to be notified
to the Department. However, the deliberate discharge of surplus or waste chemicals is not
allowed, and the chemicals should be returned to shore for disposal.
The regulations are not intended to apply to chemicals that might otherwise be used on a ship,
helicopter or other offshore structure. This effectively exempts, for example, products used solely
within accommodation areas, additives to potable water systems, paints and other coatings,
fuels, lubricants, fire-fighting foams, hydraulic fluids used in cranes and other machinery etc.
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In contrast, chemicals used for maintenance operations such as cleaning operational pipe work or
vessels, are covered by the OSPAR HMCS and the Offshore Chemicals Regulations 2002. The
use and discharge of such chemicals requires to be included in chemical permit applications.
18. Will the regulations cover risks associated with transport to (and, in some cases,
from) the platform?
No, the transport of chemicals to and from the installation would be covered by merchant shipping
legislation, codes of practice etc.
19. What would DECC expect to see in an ES in relation to chemical use and
discharge, given that it can be prepared a year in advance of offshore operations?
In some cases it is possible to provide detailed information in relation to chemical use and
discharge, and the ES should include a full chemical risk assessment. However, in most cases,
the ES will be limited to a generic assessment of chemical use, to be supported by a formal
chemical permit application submitted at a later date.
20. When an application is submitted, do FRS / CEFAS have sole responsibility for the
evaluation of the risk assessment, or does DECC have any involvement?
The DECC Environmental Manager responsible for the operator submitting the application will
coordinate the application review, and will prepare an overall assessment that takes account of
the comments provided by both internal and external consultees (including the evaluation
provided by FRS / CEFAS). All internal and external consultees will be able to comment on the
risk assessment, but the Environmental Manager will determine the application.
21. What method of analysis appropriate to determine the content of hydrocarbon
discharges & substitute chemicals?
Discharges of hydrocarbon chemicals and substitute hydrocarbon chemicals may attract a permit
condition that states “Representative samples of the discharged material shall be collected at
regular intervals during the course of the discharge operation(s), and analyses undertaken using
a method approved by the Department to determine the hydrocarbon chemical, or substitute
hydrocarbon chemical, content of the discharge(s).”
At present, it is the responsibility of the operator to decide the most appropriate analysis
methodology However, the Department would recommend using either Gas Chromatography –
Mass Spectrometry (GC-MS), Gas Chromatography – Flame Ionisation Detection (GC-FID) or
Fourier Transform Infrared Spectroscopy (FT-IR), or a combination of these techniques. If
operators do not consider these techniques to be appropriate or feasible, they should contact the
Department to discuss their proposals. Further information regarding the sampling and analysis
of produced water and other hydrocarbon discharges can be found at:
http://og.decc.gov.uk/en/olgs/cms/environment/leg_guidance/oppc/oppc.aspx
22. Well bore clean-up discharge; can waste streams be put into temporary storage
prior to discharge, and still qualify as an operational discharge?
Only operational discharges can be permitted, but it is common practice to put fluids in tanks
during clean-up (and other) operations, to sample and analyse the waste stream prior to
discharge to ensure compliance with the permit conditions.
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Interim storage may be necessary to check the quality of the waste stream prior to discharge, or
as part of the treatment regime prior to discharge. Providing the proposals are detailed in the
permit application, it would not affect their status. However, waste streams put into storage for
“skip and ship” operations would lose their operational status, and it is unlikely that the
Department would approve a subsequent application to discharge the waste at a later date,
unless there were significant technical, logistical or environmental reasons for discounting the
original “skip and ship” option.
23. TRIAL CHEMICALS – Is the use and/or discharge of trial chemicals covered by the
Regulations?
In addition to the disposal of certain surplus chemicals being covered by the OCR Regulations,
(as described in 4.26 to 4.30 of the Guidance Notes), the use and/or discharge of certain trial
chemicals can be regarded as an operational activity and can therefore be covered by a chemical
permit.
An example would be testing a cement unit with a trial mix prior to commencing a drilling
campaign.
24. Pipe Dopes containing Lead – Can they be used in the UKCS?
Discharges of these pipe dopes are prohibited, and the Department will be refusing to accept
applications that include a proposed discharge of pipe dopes containing lead. Alternative pipe
dopes that do not contain lead can be used for applications where there is an anticipated
discharge, and should continue to be assessed and entered in the application and the EEMS
return using the default 10% discharge estimate.
PON15 applications to use pipe dopes containing lead should relate to activities where there is no
planned or anticipated "discharge" of the dope, and should accordingly be entered in the
application and the EEMS return as Zero Discharge. Text should also be included in Section C of
the application to confirm the measures that will be taken to justify the zero discharge estimate
(detailing how it is being used to ensure zero discharge).
Further information in relation to the justification for continued use of pipe dopes containing lead
can be found in the second attached document, which was submitted to the OSPAR Offshore
Industries Committee meeting in 2010 and contains a supporting report prepared by O&GUK
document (‘Industry Technical Justification to DECC: Supporting the Continued Use & Discharge
of Lead-containing Pipe Dopes beyond January 2010’).
p00528_Overview
Assessment Rec 2005-2.pdf
25. The use of chemicals in shallow drilling
Shallow borehole drilling (<350 metres) for the purpose of obtaining geological information about
strata requires a consent under the Offshore Petroleum Activities (Conservation of Habitats)
Regulations 2001 (as amended), which can be applied for by submitting a PON14A. If only
PLONOR chemicals are to be used as part of the operation, the drilling operation will not require
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a separate chemical permit. If non-PLONOR chemicals are to be used, a separate chemical
permit will be required and this can be applied for by submitting a PON15B.
26. The use of abrasives during well abandonment operations
The use of abrasives to sever well elements is not covered by the HMCS and, as such, the
abrasives do not require to be certified by CEFAS under the Offshore Chemicals Notification
Scheme. Nevertheless, full details of the proposals should still be included in Section C of the
PON15 application. It is not possible to use Section G of the application to provide details of any
chemical that is not on the certified list, but approval for the use and/or discharge of such
chemicals can still be obtained by adding them to Section C. If operators wish to use a noncertified chemical but there is no requirement to seek a chemical permit for other, certified,
chemicals, operators should e-mail brief details of the proposals to DECC (via
[email protected]), and seek advice on how to proceed.
27. DISCHARGE OF CUTTINGS CONTAMINATED WITH ORGANIC PHASE DRILLING FLUIDS
The decision whether to authorise the use of hammer-mill treatment technology is made on a
case-by-case basis, and will depend upon the operator demonstrating that this represents Best
Available Technology (BAT) and Best Environmental Practice (BEP). However, this requirement
is standard procedure for all offshore operations, and the technology has now been used
routinely, and successfully, on a number of offshore installations.
Irrespective of the nature of the application process, the operator is required to provide details of
any proposed offshore use of the hammer-mill treatment technology, and to justify the proposed
use. It is also necessary to quantify the treatment and discharge requirement, including the
estimated level of Oil on Cuttings (OOC). Any chemical permit eventually issued to cover the
proposed operation will additionally include conditions relating to the proposed use and discharge
of the base-oil, and conditions relating to the sampling and analysis of the effluent scheduled for
discharge to confirm that the quality of the effluent meets the OSPAR 1% OOC standard.
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